Incoterms 2020 for petroleum buyers: FOB, CIF, DDP
Who pays the freight, who carries the risk, and when title passes. The three letters that decide it.
A petroleum trade is a chain of promises about money and molecules. When those promises sit under a legal system a London or Frankfurt bank already understands, the whole chain becomes cheaper to finance and easier to enforce. That is the quiet reason Cheka is built inside the Astana International Financial Centre.
The Astana International Financial Centre, the AIFC, is a financial jurisdiction that opened in 2018 inside Kazakhstan but sits apart from the national court system. Its founding law carves out an English-language, common-law zone with its own court and its own arbitration centre. The rules are modelled on English commercial law rather than translated from a civil code, and the senior judges are drawn from England, Wales, and other common-law benches.
For a trading house registered there, as Cheka was in September 2024, that matters in a practical way. Contracts, disputes, and the security behind a cargo all run on principles that have been tested in the world's busiest commercial courts for more than a century. A buyer does not have to learn a new rulebook to do business with us. They already know it.
Trade finance is priced on risk, and legal risk is one of the largest lines in that price. A bank issuing a letter of credit, or a lender advancing against a cargo, wants to know exactly what happens if a counterparty fails to perform. Under English common law those answers are largely settled: how title passes, how a lien works, when a force majeure clause bites, and what a court will do with an ambiguous term. There is a deep library of precedent, so very few questions are genuinely new.
A contract is only as strong as the court that stands behind it.
Every Cheka sale sits on the same spine. The governing law is English common law as applied in the AIFC. Disputes go to the AIFC Court or to arbitration under the International Arbitration Centre, both seated in Astana and conducted in English. Incoterms 2020 set the delivery point and the moment risk passes, an independent inspector such as SGS certifies quality and quantity at the load port, and payment usually moves through a documentary letter of credit.
None of these pieces is exotic. A buyer's counsel in Rotterdam or Singapore can open a Cheka contract and recognise every clause. That recognition is worth money. It means faster credit approval, cleaner enforcement if a shipment goes wrong, and less friction on the terms that matter most. In commodities something eventually does go wrong, and when it does the path back to a remedy is already mapped rather than argued from scratch.
The point of the AIFC is not to move a company somewhere convenient and hope no one asks questions. It is to stand behind a trade in a forum global capital already trusts. Kazakhstan sits on real reserves and a real refining base, at the meeting point of Central Asian supply and world demand. Pairing that physical reality with a common-law court gives a counterparty the two things they need at once: barrels that exist and a rulebook that holds.
Who pays the freight, who carries the risk, and when title passes. The three letters that decide it.
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